Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks Aviva Glaser and Patty Glick 2012 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 1 Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks Prepared by Aviva Glaser, Legislative Representative, Agriculture Policy Patty Glick, Senior Climate Change Specialist Acknowledgements This report was made possible due to the generous support of the Doris Duke Charitable Foundation. The authors wish to thank many people for their time and contributions to this report. We would like to thank the following National Wildlife Federation staff for providing valuable edits and feedback: Julie Sibbing, Bruce Stein, Doug Inkley, and Lara Bryant. Additionally, we would like to thank several experts for their time, input, and helpful review comments: Dr. Joseph DiTomaso, University of California, Davis; Dr. Doria Gordon, The Nature Conservancy; Bryan Endres, J.D., University of Illinois; Dr. Lauren Quinn, University of Illinois; Doug Johnson, California Invasive Plant Council; and Read Porter, J.D., Environmental Law Institute. Designed by Maja Smith, MajaDesign, Inc. © 2012 National Wildlife Federation Cover image: The highly-invasive giant reed (Arundo donax), a candidate species for bioenergy production, has taken over vast areas along the Rio Grande, as seen in this aerial view near Eagle Pass, Texas. Credit: John Goolsby, USDA. Suggested citation: Glaser, A. and P. Glick. 2012. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks. Washington, DC: National Wildlife Federation. i Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Table of Contents Little bluestem, a native grass. Credit: NRCS. 1. Executive Summary 1 2. Overview 3 The Promise of Bioenergy 3 Risks from Bioenergy 4 A Focus on Invasiveness 4 3. Invasive Bioenergy Feedstocks: A Major Concern 7 Invasive Plans Can Wreak Havoc on Ecosystems and Society 7 Weediness: A Characteristic of a “Good” Biomass Plant 8 Harvesting Existing Invasive Plants: Win-Win or Pandora’s Box? 9 Adding Climate Change to the Mix 10 Selective Breeding and Genetic Modification 11 The Myth of Total Sterility 12 4. Case Studies of Feedstocks of Concern 14 Giant Reed (Arundo donax) 14 Miscanthus (Miscanthus species) 16 Genetically Modified Eucalyptus (Eucalyptus grandis x Eucalyptus urophylla) 18 Reed Canarygrass (Phalaris arundinacea) 20 Algae 22 Napiergrass (Pennisetum purpureum) 24 5. Minimizing the Risks: The Importance of Embracing Precaution 26 Current Regulation of Invasive Species 26 Screening Tools 32 6. Conclusions and Recommendations 34 Concluding Thoughts 41 7. Endnotes 42 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks ii 1 Executive Summary ithout question, America needs to transition to a cleaner, more sustainable W energy future. As we move forward with our energy choices, we must be mindful of how short- term economic decisions can come with unintended consequences and high long-term costs to society and the environment. Bioenergy is one homegrown source of renewable energy that could help meet some of our energy needs. However, in order to create a truly clean energy future, bioenergy must be produced in a way that has long-term economic viability, helps address climate change, and protects and enhances native habitats and ecosystems. The explosion in federal and state mandates and incentives for renewable energy in recent years has led to a greatly increased demand for cheap and plentiful biomass from a variety of plants and micro- organisms. This increased demand for bioenergy has led to considerable interest in a number of non-native and potentially invasive species that are currently being cultivated or considered for use as bioenergy crops. In fact, some of the very characteristics that make a plant particularly useful as a source of biomass energy (e.g., rapid growth, competitiveness, tolerance of a range of climate conditions) are the same characteristics that Parabel grows non-genetically modified, native aquatic make a plant a potentially highly invasive species. plants in Florida to use as a renewable energy feedstock. Credit: Julie Sibbing. Widespread cultivation of exotic and genetically modified species for bioenergy is becoming increasingly likely. In order to create a truly clean energy Should these species escape cultivated areas and enter nearby habitats, the results could be devastating for future, bioenergy must be produced in a native ecosystems as well as the economy. Very little is way that has long-term economic viability, known about the full potential scope of the problem, yet the industry is moving full speed ahead. Already, there helps address climate change, and are examples of intentional cultivation of biomass species that are known to be invasive or have the potential to protects and enhances native habitats become invasive. For instance: and ecosystems. 4 • Giant reed (Arundo donax) is being used as a bioenergy As a result, invasive species that we may have been able crop in Florida, despite the fact that it has been known to inhibit are causing widespread environmental and to invade important riparian ecosystems and displace economic harm. habitat for native species in states across the southern half of the country. We now have an opportunity to prevent irreparable harm by heeding sensible precautions. With foresight and careful • Reed canarygrass (Phalaris arundinacea), which is screening, we have important opportunities to minimize considered to be one of the most harmful invasive species and, where possible, prevent negative impacts of biomass in America’s wetlands, rivers, and lakes, is being proposed feedstocks on the nation’s communities and ecosystems. for cultivation as a bioenergy feedstock in several areas, We recommend some key actions to help ensure that the including the Eastern Upper Peninsula of Michigan. next generation of bioenergy does not fuel the next invasive species problem. • Cylindro (Cylindrospermopsis raciborskii), a type of algae that is associated with toxic algal blooms in the Great 1. Future bioenergy development should encourage Lakes region, is just one of many non-native or modified ecological restoration and improve wildlife habitat through strains of algae under consideration for bioenergy, even the use of ecologically beneficial biomass feedstocks such though the fast growth rate of algae and the inherent as waste materials and sustainably collected native plants difficulty in containing them is a major concern. and forest residues. • Napiergrass (Pennisetum purpureum), also called 2. Federal and state governments should conduct elephant grass, has been listed as an invasive plant coordinated efforts to restrict or prohibit the use of in Florida and described as one of the most problematic known invasive species as dedicated bioenergy weeds in the world, and yet BP is currently developing feedstocks through rigorous Weed Risk Assessment a cultivated variety of it as an energy crop in the Gulf (WRA) screening protocols. Coast Region. 3. State and federal governments should implement In addition, the use of already highly-destructive invasive rigorous monitoring, early detection, and rapid response plants for bioenergy, including Chinese tallow (Triadica protocols, paid for by feedstock producers through sebifera), kudzu (Pueraria montana var. lobata), Eurasian insurance bonding or other financial mechanisms. watermilfoil (Myriophyllum spicatum), and common reed (Phragmites australis), is being proposed as a way to 4. Feedstock producers should adopt best management capitalize on the potential benefits of the plants while plans for monitoring and mitigation to reduce the risk providing an opportunity for their control. While this of invasion. may allow for a win-win for ecosystem restoration and renewable energy production, it also raises the concern 5. The federal government should assign liability to that the active re-establishment of the invasive species, feedstock producers for damages from and remediation of rather than their control, might be incentivized. invasions by feedstock varieties that they develop. The severity of this threat is by no means trivial. Every 6. Governments and businesses should better account year, invasive species cost the United States billions of for the economic risks associated with invasiveness of dollars and affect countless acres of native ecosystems. feedstocks when assessing relevant costs and benefits of Researchers estimate that nearly half of the species listed potential bioenergy projects. as threatened or endangered under the U.S. Endangered Species Act are at risk, at least in part, due to the impacts Bioenergy can be an important part of a sustainable energy of invasive species. Despite this, few safeguards exist future, but only if it is produced in a way that safeguards in law and in practice to prevent the spread of invasive native ecosystems and minimizes the risk of invasion. species. To date, current laws and regulations dealing with invasive species have been reactive and piecemeal. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 2 2 Overview s the world focuses greater attention on finding alternatives to fossil fuels in order to A meet our growing energy demands, reduce carbon emissions, and enhance global security, interest in expanding the use of bioenergy has grown considerably. Bioenergy – also called biomass energy – refers to the energy resources derived from plants